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#1 Do you have anything in writing? Or do you have a witness to what he agreed to?
#2 If not, take all the documentary evidence you have and do your best to stiff him in small claims court. They don't care about side issues such as software licenses, just who has promised whom how much money and who hasn't paid it. It's just so much better if you have stock that he won't honor or even admit he has issued. Yowsa, now you're getting to the Fed level.
What do you have in evidence? That is the main issue in your case. If you have evidence to what he has promised but hasn't delivered, then you should have no problem with getting a favorable solution.
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(none yet, still thinkin')
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